Overview
- The Supreme Court, in a 6–3 opinion written by Justice Samuel Alito issued Thursday, June 25, 2026, held that Hawaii’s Act 52 violated the Second and Fourteenth Amendments and remanded the case to the Ninth Circuit for further proceedings.
- Act 52 created a default rule that barred licensed concealed‑carry holders from entering private property open to the public without the property owner’s express permission, a practice critics called the 'vampire rule.'
- Applying the Bruen framework from 2022, the majority found Hawaii’s historical analogues were too dissimilar to justify the modern ban and rejected the state’s reliance on colonial antipoaching laws and an 1865 Louisiana statute.
- The ruling directly affects other states with similar default private‑property carry rules, and it is likely to prompt new lawsuits, prompt courts to revisit existing statutes, and push legislatures to rewrite carry and signage rules.
- Justices in dissent defended the law as protecting property owners’ right to exclude, and the decision will change daily life for permit holders who no longer face a statutory presumption that private public‑access spaces are gun‑free while also intensifying political and advocacy fights over public‑place gun limits.